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Using Your domain Name in China

Thomas Kuiper

At Gandi, we offer over 750 TLD's right now (probably the one with the most coverage in the industry) so we often see changes in policy first hand.

One of these changes was the introduction of new laws in China and regulations by the MIIT (China’s Ministry of Industry and Information Technology) in late 2017. We updated our customers on these new regulations to hopefully avoid some confusion, and I'd like to share them here as well.

Gandi has been accredited by CNNIC since 2015, allowing us to sell .CN domains (the country top-level domain name for China) to our customers worldwide.

At CNNIC, we are listed as an overseas registrar. As you probably know, owning a .CN domain name requires that the domain name contains the registrant’s real name and also needs to pass an additional verification process by CNNIC (using the owner's passport or ID). This process hasn’t changed. CNNIC has been under the management by the MIIT for a few years now. But that doesn’t necessarily mean Gandi is now a so-called “MIIT accredited registrar” (yet), even if we can support you perfectly in Chinese thanks to our team in Taipei.

If you are not hosting data within China (meaning you are using a Gandi VPS or our PaaS outside of China), there are no additional steps required to register your .CN domain name.

However, if you intend to host your data with a Cloud hosting provider within China (and sell to customers in China), they may ask you to transfer your domain name to an MIIT-accredited registrar. Only companies in China can currently become an “MIIT-accredited registrar.” Since Gandi doesn’t have an office in China, we are not MIIT accredited.

We are in, however, checking with CNNIC about whether this policy can be changed. Please note that the domain owner must also be a legal entity in China (or China resident) if you are hosting data in China.

A domain name must then undergo something called ICP verification (ICP Filling or ICP License depending on the use).

Although MIIT removed the clause specifying that the registrar must be in China from the draft of the new China Cyberspace regulations, the local MIIT offices (which undertake ICP verification) may still insist that your registrar that uses your domain name is in China. This is odd as many registrars in China do not offer every top-level domain name, let alone all the additional services that Gandi provides such as DNSSEC, global DNS infrastructure, and services like Gandi Mail and Web Forwarding. In addition, not every top-level domain name offers real name verification. The process to have your ICP license or filling can, therefore, be rather complicated as of now.

Mandatory real name verification also applies to .COM and other domain names (which until then technically weren’t legal to use within China although Baidu.com, Taobao.com, use a .COM domain name). CNNIC made a deal with Verisign (.COM & .NET) to allow it for them.

Given the information above, we currently recommend the following:

  • If you intend to sell to customers in China on your website with Chinese IP address, make sure the owner contacts are with your partner in China
  • If you still encounter issues during ICP Filling or ICP License requests you will have to transfer your domain to a domestic registrar. Laws in China change often and hopefully these restrictions are lifted someday soon
  • Alternatively, do not use a hosting provider in China but understand the risk that your website may be blocked if it contains sensitive or harmful materials (n.b. the definition can be very broad)
  • Make use of multiple consultants to register your ICP license or conduct your ICP filling. Rules vary by province!

Have you encountered issues using your domain name in China? We’d like to hear from you at feedback[at]gandi.net.

You may also reach out to me on Linkedin or via CircleID.

By Thomas Kuiper, General manager, Gandi Asia Co. Ltd (Gandi.net)
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